A workaround could be to implementing a shared library to load using
LD_PRELOAD, which could provide a fcntl() wrapper masking the lack of
F_OFD_SETLKW in WSL 1 by implementing the same broken locking mechanism
as F_SETLK?  Then one could use `LD_PRELOAD=brokenwsllocking apt
upgrade` or similar to upgrade systemd when using WSL 1.

-- 
Happy hacking
Petter Reinholdtsen

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